ZURAW FINANCIAL ADVISORS, LLC

Item 1: Cover Page Item 1: Cover Page Part 2A of Form ADV Firm Brochure October 27, 2025 Zuraw Financial Advisors, LLC SEC File No. 801-80364 806 Green Valley Road, Suite 201 Greensboro, NC 27408 phone: 336-496-8961 email: azuraw@zurawfinancialadvisors.com website: www.ZurawFinancialAdvisors.com This brochure provides information about the qualifications and business practices of Zuraw Financial Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at 336- 290-7062. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration with the SEC or state regulatory authority does not imply a certain level of skill or expertise. Additional information about Zuraw Financial Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Page 1 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 2: Material Changes Item 2: Material Changes This Firm Brochure is our disclosure document prepared according to regulatory requirements and rules. Consistent with the rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. There are no material changes to this Brochure from the last annual update issued on March 5, 2025. Page 2 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 3: Table of Contents Item 3: Table of Contents Item 1: Cover Page ...................................................................................................................................................... 1 Item 2: Material Changes .......................................................................................................................................... 2 Item 3: Table of Contents ......................................................................................................................................... 3 Item 4: Advisory Business ......................................................................................................................................... 4 Item 5: Fees and Compensation ............................................................................................................................ 8 Item 6: Performance-Based Fees and Side-by-Side Management ......................................................... 11 Item 7: Types of Clients ........................................................................................................................................... 12 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................................................. 13 Item 9: Disciplinary Information ........................................................................................................................... 23 Item 10: Other Financial Industry Activities and Affiliations ........................................................................ 24 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................................................................................................................................... 25 Item 12: Brokerage Practices ................................................................................................................................... 27 Item 13: Review of Accounts ................................................................................................................................... 34 Item 14: Client Referrals and Other Compensation ........................................................................................ 35 Item 15: Custody .......................................................................................................................................................... 36 Item 16: Investment Discretion ............................................................................................................................... 37 Item 17: Voting Client Securities ............................................................................................................................ 38 Item 18: Financial Information ................................................................................................................................ 39 Page 3 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 4: Advisory Business Item 4: Advisory Business A. Zuraw Financial Advisors, LLC Zuraw Financial Advisors, LLC (“ZFA” and/or “the firm”) is organized as a North Carolina limited liability company and Ann Zuraw is the sole principal owner. ZFA has been offering investment advisory services since 2013. B. Advisory Services Offered Portfolio Management At the beginning of a client relationship, ZFA meets with the client, gathers information and performs research and analysis as necessary to develop the client’s Investment Plan. The Investment Plan outlines the types of investments ZFA will make on behalf of the client in order to meet those goals. The Plan will be updated from time to time when requested by the client, or when determined to be necessary or advisable by ZFA based on updates to the client’s financial or other circumstances. The Plan is discussed regularly with each client, but is not necessarily a written document. In addition, ZFA, pursuant to the terms of its investment advisory agreement with clients, may engage third-party separate account managers to manage all or a portion of the client’s portfolio. For its discretionary asset management services, ZFA receives a limited power of attorney to effect securities transactions on behalf of its clients that include securities and strategies described in Item 8 of this brochure. ZFA’s discretionary asset management services are predicated on the client's investment objectives, goals, tolerance for risk, and other personal and financial circumstances. ZFA will analyze each client's current investments, investment objectives, goals, age, time horizon, financial circumstances, investment experience, investment restrictions and limitations, and risk tolerance and implement a portfolio consistent with such investment objectives, goals, risk tolerance and related financial circumstances ZFA’s objective is to review the client’s tax, financial, and estate planning objectives and goals in connection with the client’s investment objectives, goals, tolerance for risk, and other personal and financial circumstances and make appropriate recommendations and implementation decisions. In addition, ZFA may utilize third- party software to analyze individual security holdings and separate account managers utilized within the client’s portfolio. ZFA’s investment advisory services to clients take into account a client's personal financial circumstances, investment objectives and tolerance for risk (e.g., cash-flow, tax and estate). ZFA’s engagement with a client will include, as appropriate, the following: ▪ Providing assistance in reviewing the client's current investment portfolio against the client's personal and financial circumstances as disclosed to ZFA in response to a questionnaire and/or in discussions with the client and reviewed in meetings with ZFA. Page 4 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 4: Advisory Business ▪ Analyzing the client's financial circumstances, investment holdings and strategy, and goals. ▪ Providing assistance in identifying a targeted asset allocation and portfolio design. ▪ Implementing and/or recommending individual equity and fixed income securities, mutual funds and ETFs. ▪ Providing access to the Advyzon portal where clients will have access to their account information and performance. ▪ Proposing changes in the client's investment portfolio in consideration of changes in the client's personal circumstances, investment objectives and tolerance for risk, the performance record of any of the client's investments, and/or the performance of any fund retained by the client. Clients have the right to provide the firm with any reasonable investment restrictions on the management of their portfolio, which must be in writing and sent to the firm. Clients should promptly notify the firm in writing of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. ZFA will remind clients of their obligation to inform the firm of any such changes or any restrictions that should be imposed on the management of the client’s account. ZFA will also contact clients at least annually to determine whether there have been any changes in a client's personal financial circumstances, investment objectives and tolerance for risk. Retirement Rollovers – Conflicts and Added Fees. Plan participants may be paying little or nothing for the plan’s investment services. As such, investment management costs are likely to be higher when engaging an investment adviser for professional investment management. Alternative courses of action are available to the plan participant: (i) Assuming it is permitted by the Plan, you can leave your money in your current Plan. (ii) If you have changed employers, you can roll your assets into the new employer’s Plan, if permissible by your new employer. (iii) You can establish an IRA R/O and place into a commission-based account at a broker-dealer. (iv) You can establish an IRA R/O and place into a fee-based advisory account. (v) You can withdraw your retirement money and pay the taxes and any applicable penalties. Your decision to roll assets from a qualified plan to a financial professional should be determined by your need for a desired level of investment services, the associated costs, and access to a diverse range of investment products that meet your personal risk tolerance and investment objective. Selection of Other Advisers (Sub-Advisers) As part of its portfolio management services, ZFA may recommend one or more third-party sub- advisers to manage all or a portion of the client's investment portfolio. Factors taken into consideration when making recommendations include, but are not limited to, the sub-adviser’s performance, investment strategies, methods of analysis, advisory and other fees, assets under management, and the client's financial objectives and risk tolerance. ZFA would generally retain authority to hire/fire the sub-adviser and regularly monitors the performance of the sub-adviser to ensure its management and investment style remain aligned with the client's objectives and risk tolerance. Page 5 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 4: Advisory Business ZFA has sub-advisory agreements with unaffiliated registered investment advisers and platform providers. ZFA accesses various investment strategies made available through the sub-advisers’ investment platforms. ZFA determines which strategies the client assets are to be invested in, and thereafter the sub-adviser implements all trades necessary to cause such assets to be invested in the strategies. ZFA continuously manages any sub-adviser relationship and regularly monitors the client's account(s) for performance metrics and adherence to the client's investment objectives. Each sub-adviser maintains a separate disclosure document that ZFA will provide to the client. The client should carefully review the sub-adviser's disclosure document for information regarding fees, risks and investment strategies, and conflicts of interest. The sub-adviser’s fee will be in addition to the advisory fees charged by ZFA. Financial Planning At the outset of each client relationship, ZFA spends time with the client, asking questions, discussing the client’s investment experience and financial circumstances, and reviewing options for the client. Based on its reviews, ZFA will develop a financial outline for the client based on the client’s financial circumstances and goals, and the client’s risk tolerance level (the “Financial Profile”). The Financial Profile is a reflection of the client’s current financial picture and a look to the future goals of the client. The Profile is discussed regularly with each client, but is not necessarily a written document. ZFA’s financial planning services generally include an analysis of a client’s overall financial condition and investment needs; an analysis of net worth, asset distribution, asset growth and cash flow; estate, education, retirement, stock options and other funding needs; asset allocation strategies; investment portfolio valuation and planning; and a review of life insurance death benefit needs. These services may also include limited consultations with other professionals assisting the client, such as the client’s attorney or tax adviser. Where ZFA provides general consulting services, ZFA will work with the client to prepare an appropriate summary of the specific project(s) to the extent necessary or advisable under the circumstances. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives and in accordance with any reasonable restrictions imposed by the client on the management of the account—for example, restricting the type or amount of security to be purchased in the portfolio. D. Wrap Fee Programs ZFA does not participate in wrap fee programs. (Wrap fee programs offer services for one all- inclusive fee.) Page 6 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 4: Advisory Business E. Client Assets Under Management As of December 31, 2024, ZFA managed $444,727,224 on a discretionary basis, and no assets on a non‐discretionary basis. Page 7 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 5: Fees and Compensation Item 5: Fees and Compensation A. Methods of Compensation and Fee Schedule Portfolio Management & Sub-Adviser Fees ZFA’s fee for portfolio management services is an asset-based fee calculated as a percentage of the value of the managed assets according to the Investment Advisory Agreement, Exhibit A Fee Schedule, which represents the maximum fees for individual services. All fees are negotiable. ZFA charges a maximum annual fee of 1.00%, which includes ZFA’s advisory fee plus applicable sub-adviser and platform fees if a sub-adviser is utilized. ZFA generally requires a minimum account size of $250,000. ZFA may, at its discretion, make exceptions to the foregoing or negotiate special fee arrangements where ZFA deems it appropriate under the circumstances. Sub-adviser fees vary depending on the platform and strategy(ies) selected. ZFA has an economic incentive to recommend those strategies that yield the highest fees to ZFA. While ZFA prioritizes clients’ best interests, it’s important to be aware of this conflict of interest during the construction of the client’s investment portfolio. Clients should note that comparable services may be available elsewhere at more favorable pricing. Clients are encouraged to discuss with their financial professional the most appropriate tier of services, given the client’s needs and the applicable cost given the client’s investment goals and objectives. Asset-based fees are always subject to the investment advisory agreement between the client and ZFA. Such fees are payable quarterly in advance. The fees will be prorated if the investment advisory relationship commences otherwise than at the beginning of a calendar month. Adjustments for significant contributions to a client’s portfolio are prorated for the quarter in which the change occurs; no adjustments will be made for withdrawals. The client authorizes the qualified custodian to automatically deduct the fee and all other charges payable hereunder from the assets in the account when due with such payments to be reflected on the next account statement sent to the client. If insufficient cash is available to pay such fees, securities in an amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. ZFA may modify the fee at any time upon 30 days’ written notice to the client. In the event the client has an ERISA-governed plan, fee modifications must be approved in writing by the client. A client investment advisory agreement may be canceled by either party with 30 days’ prior written notice. Upon termination, any unearned, prepaid fees will be refunded at the next quarterly billing cycle. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. Financial Planning & Consulting Fees Financial planning and general consulting fees will be billed at a fixed fee mutually agreed upon by the client and ZFA. ZFA will provide the prospective client with an estimate of the fixed charges prior to finalizing the agreement. The client will be billed directly for such services. Invoices will be mailed out on a periodic basis reflecting completed work performed. A client Page 8 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 5: Fees and Compensation financial planning or consulting agreement may be terminated by either party with 10 days’ prior written notice. The agreement will also be terminated immediately upon the termination of the investment advisory agreement between ZFA and the client. Upon termination, the fees will be prorated based on the approximate percentage of work completed, and shall become immediately due and payable; with respect to any fees paid in advance, such prorated portion shall be refunded to the client. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. The client will receive a full credit for a financial planning fee if: (i) within three months of entering into the financial planning agreement he/she places $250,000 under management with the firm, and (ii) the management of such assets lasts for at least one year. B. Client Payment of Fees ZFA requires clients to authorize the direct debit of fees from their accounts. Exceptions may be granted subject to the firm’s consent for clients to be billed directly for our fees. For directly debited fees, the custodian’s periodic statements will show each fee deduction from the account. Clients may withdraw this authorization for direct billing of these fees at any time by notifying us or their custodian in writing. ZFA will deduct advisory fees directly from the client’s account provided that (i) the client provides written authorization to the qualified custodian, and (ii) the qualified custodian sends the client a statement, at least quarterly, indicating all amounts disbursed from the account. The client is responsible for verifying the accuracy of the fee calculation, as the client’s custodian will not verify the calculation. C. Additional Client Fees Charged All fees paid for investment advisory services are separate and distinct from the fees and expenses charged by exchange-traded funds, mutual funds, separate account managers, broker- dealers, and custodians retained by clients. Such fees and expenses are described in each exchange-traded fund and mutual fund’s prospectus, and each separate account manager’s Form ADV and Brochure and Brochure Supplement or similar disclosure statement, and by any broker-dealer or custodian retained by the client. Clients are advised to read these materials carefully before investing. A client using ZFA may be precluded from using certain mutual funds or separate account managers because they may not be offered by the client's custodian. Please refer to the Brokerage Practices section (Item 12) for additional information regarding the firm’s brokerage practices. D. Prepayment of Client Fees ZFA generally requires fees to be prepaid on a quarterly basis. ZFA’s fees will either be paid directly by the client or disbursed to ZFA by the qualified custodian of the client’s investment accounts, subject to prior written consent of the client. The custodian will deliver directly to the Page 9 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 5: Fees and Compensation client an account statement, at least quarterly, showing all investment and transaction activity for the period, including fee disbursements from the account. A client investment advisory agreement may be canceled by either party with 30 days’ prior written notice. Upon termination, any unearned, prepaid fees will be refunded at the next quarterly billing cycle. The client has the right to terminate an agreement without penalty within five business days after entering into the agreement. E. External Compensation for the Sale of Securities to Clients ZFA’s advisory professionals are compensated primarily through a salary and bonus structure. ZFA is not paid any sales, service or administrative fees for the sale of mutual funds or any other investment products with respect to managed advisory assets. Page 10 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 6: Performance-Based Fees and Side-by-Side Management Item 6: Performance-Based Fees and Side-by-Side Management ZFA does not charge performance-based fees and therefore has no economic incentive to manage clients’ portfolios in any way other than what is in the clients’ best interests and the firm acting under its fiduciary obligations. Page 11 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 7: Types of Clients Item 7: Types of Clients ZFA serves individuals including high-net-worth individuals, trusts, estates, corporations and other legal entities. ZFA generally requires a minimum account size of $250,000. Under certain circumstances and in its sole discretion, ZFA may negotiate such minimums. Page 12 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies In accordance with the Investment Plan, ZFA primarily invests in ETFs, common stocks, mutual funds and individual bonds (government, corporate and municipal) for client accounts. Mutual funds and ETFs are generally evaluated and selected based on a variety of factors, including, without limitation, past performance, fee structure, portfolio manager, fund sponsor, overall ratings for safety and returns, and other factors. In selecting individual stocks for an account, ZFA generally applies traditional fundamental analysis, which involves a review of the business and financial information about an issuer. Financial strength ratios, price-to-earnings ratios, dividend yields, and other areas are commonly reviewed. ZFA may also use stock screening techniques, discounted cash flow modeling, research databases such as Advyzon, or third-party analyst reports. Fixed income investments may be used as a strategic investment, as an instrument to fulfill liquidity or income needs in a portfolio, or to add a component of capital preservation. ZFA may evaluate and select individual bonds or bond funds based on a number of factors including, without limitation, rating, yield and duration. ZFA’s strategic approach is to invest each portfolio in accordance with the plan that has been developed specifically for each client. This means that the following strategies may be used in varying combinations over time for a given client, depending upon the client’s individual circumstances. ▪ Long Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. ▪ Short Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short term price fluctuations. Management Risks. While ZFA manages client investment portfolios based on ZFA’s experience, research and proprietary methods, the value of client investment portfolios will change daily based on the performance of the underlying securities in which they are invested. Accordingly, client investment portfolios are subject to the risk that ZFA allocates assets to asset classes that are adversely affected by unanticipated market movements, and the risk that ZFA’s specific investment choices could underperform their relevant indexes. Risk of Loss: While ZFA seeks to diversify clients’ investment portfolios across various asset classes consistent with their Investment Plans in an effort to reduce risk of loss, all investment portfolios are subject to risks. Accordingly, there can be no assurance that client investment portfolios will be able to fully meet their investment objectives and goals, or that investments will not lose money. Page 13 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Third-Party Sub-Advisers ZFA may assist the client in selecting one or more appropriate sub-advisers for all or a portion of the client’s portfolio. Such sub-advisers will typically manage assets for clients who commit to the manager a minimum amount of assets established by that sub-adviser—a factor that ZFA will take into account when recommending sub-advisers to clients. ZFA 's selection process cannot ensure that sub-advisers will perform as desired, and ZFA will have no control over the day-to-day operations of any of its selected sub-advisers. ZFA would not necessarily be aware of certain activities at the underlying sub-advisers level, including without limitation a sub-adviser’s engaging in unreported risks, investment “style drift,” or even regulatory breaches or fraud. A description of the criteria to be used in formulating an investment recommendation for sub- advisers is set forth below. ZFA has formed relationships with third-party vendors that ▪ provide a technological platform for separate account management ▪ prepare performance reports ▪ perform or distribute research of individual securities ▪ perform billing and certain other administrative tasks ZFA may utilize additional independent third parties to assist it in recommending and monitoring sub-advisers to clients as appropriate under the circumstances. ZFA reviews certain quantitative and qualitative criteria related to managers and to formulate investment recommendations to its clients. Quantitative criteria may include ▪ performance history of a sub-adviser evaluated against that of its peers and other benchmarks ▪ analysis of risk-adjusted returns ▪ analysis of the manager’s contribution to the investment return (e.g., manager’s alpha), standard deviation of returns over specific time periods, sector and style analysis ▪ sub-adviser’s fee structure ▪ relevant portfolio manager’s tenure Qualitative criteria used in selecting/recommending sub-advisers include the investment objectives and/or management style and philosophy of a sub-adviser; a sub-adviser’s consistency of investment style; and employee turnover and efficiency and capacity. Quantitative and qualitative criteria related to sub-advisers are reviewed by ZFA on a quarterly basis or such other interval as appropriate under the circumstances. In addition, sub-advisers are reviewed to determine the extent to which their investments reflect any of the following: efforts to time the market, engage in portfolio pumping, or evidence style drift such that their portfolios no longer accurately reflect the particular asset category attributed to the sub-adviser by ZFA (all negative factors in implementing an asset allocation structure). ZFA may negotiate reduced account minimum balances and reduced fees with sub-advisers under various circumstances (e.g., for clients with minimum level of assets committed to the sub-adviser for specific periods of time, etc.). There can be no assurance that clients will receive Page 14 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss any reduced account minimum balances or fees, or that all clients, even if apparently similarly situated, will receive any reduced account minimum balances or fees available to some other clients. Also, account minimum balances and fees may significantly differ between clients. Each client’s individual needs and circumstances will determine portfolio weighting, which can have an impact on fees given the sub-advisers utilized. ZFA will endeavor to obtain equal treatment for its clients with sub-advisers, but cannot assure equal treatment. ZFA will regularly review the activities of sub-advisers utilized for the client. Clients that engage sub-advisers should first review and understand the disclosure documents of those sub-advisers, which contain information relevant to such retention or investment, including information on the methodology used to analyze securities, investment strategies, fees, and conflicts of interest. Material Risks of Investment Instruments ZFA typically invests in open-end mutual funds and exchange-traded funds for the vast majority of its clients. However, for certain clients, ZFA may effect transactions in the following types of securities: ▪ Equity securities ▪ Mutual fund securities ▪ Exchange-traded funds ▪ Fixed income securities ▪ Corporate debt securities, commercial paper, and certificates of deposit ▪ Municipal securities ▪ U.S. government securities ▪ Corporate debt obligations ▪ Preferred Securities ▪ Convertible Securities ▪ Structured Products Equity Securities Investing in individual companies involves inherent risk. The major risks relate to the company’s capitalization, quality of the company’s management, quality and cost of the company’s services, the company’s ability to manage costs, efficiencies in the manufacturing or service delivery process, management of litigation risk, and the company’s ability to create shareholder value (i.e., increase the value of the company’s stock price). Foreign securities, in addition to the general risks of equity securities, have geopolitical risk, financial transparency risk, currency risk, regulatory risk and liquidity risk. Mutual Fund Securities Investing in mutual funds carries inherent risk. The major risks of investing in a mutual fund include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the amount of individual company diversification, the type and amount of industry diversification, and the type and Page 15 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss amount of sector diversification within specific industries. In addition, mutual funds tend to be tax inefficient and therefore investors may pay capital gains taxes on fund investments while not having yet sold the fund. ZFA recommends portfolios consisting of mutual funds offered by Dimensional Fund Advisors (“DFA”). The DFA portfolios are a blend of DFA mutual funds that provide exposure to publicly traded stocks, bonds, and cash/equivalent investments. DFA mutual funds follow a passive asset class investment philosophy with low holdings turnover. DFA provides historical market analysis, risk/return analysis, and continuing education to ZFA. This analysis considers the characteristics of the overall model portfolio rather than each fund in isolation. Model portfolios have been constructed for the following objectives: balanced, growth with income, and aggressive growth. Exchange-Traded Funds (“ETFs”) ETFs are investment companies whose shares are bought and sold on a securities exchange. An ETF holds a portfolio of securities designed to track a particular market segment or index. Some examples of ETFs are SPDRs®, NASDAQ 100 Index Tracking StockSM (“QQQs SM”) iShares® and VIPERs®. The funds could purchase an ETF to gain exposure to a portion of the U.S. or foreign market. The funds, as a shareholder of another investment company, will bear their pro-rata portion of the other investment company’s advisory fee and other expenses, in addition to their own expenses. Investing in ETFs involves risk. Specifically, ETFs, depending on the underlying portfolio and its size, can have wide price (bid and ask) spreads, thus diluting or negating any upward price movement of the ETF or enhancing any downward price movement. Also, ETFs require more frequent portfolio reporting by regulators and are thereby more susceptible to actions by hedge funds that could have a negative impact on the price of the ETF. Certain ETFs may employ leverage, which creates additional volatility and price risk depending on the amount of leverage utilized, the collateral and the liquidity of the supporting collateral. Further, the use of leverage (i.e., employing the use of margin) generally results in additional interest costs to the ETF. Certain ETFs are highly leveraged and therefore have additional volatility and liquidity risk. Volatility and liquidity can severely and negatively impact the price of the ETF’s underlying portfolio securities, thereby causing significant price fluctuations of the ETF. Fixed Income Securities Fixed income securities carry additional risks than those of equity securities described above. These risks include the company’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds have liquidity and currency risk. Page 16 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Corporate Debt, Commercial Paper and Certificates of Deposit Fixed income securities carry additional risks than those of equity securities described above. These risks include the company’s ability to retire its debt at maturity, the current interest rate environment, the coupon interest rate promised to bondholders, legal constraints, jurisdictional risk (U.S or foreign) and currency risk. If bonds have maturities of ten years or greater, they will likely have greater price swings when interest rates move up or down. The shorter the maturity the less volatile the price swings. Foreign bonds also have liquidity and currency risk. Commercial paper and certificates of deposit are generally considered safe instruments, although they are subject to the level of general interest rates, the credit quality of the issuing bank and the length of maturity. With respect to certificates of deposit, depending on the length of maturity there can be prepayment penalties if the client needs to convert the certificate of deposit to cash prior to maturity. Municipal Securities Municipal securities carry additional risks than those of corporate and bank-sponsored debt securities described above. These risks include the municipality’s ability to raise additional tax revenue or other revenue (in the event the bonds are revenue bonds) to pay interest on its debt and to retire its debt at maturity. Municipal bonds are generally tax free at the federal level, but may be taxable in individual states other than the state in which both the investor and municipal issuer is domiciled. U.S. Government Securities U.S. government securities include securities issued by the U.S. Treasury and by U.S. government agencies and instrumentalities. U.S. government securities may be supported by the full faith and credit of the United States. Corporate Debt Obligations Corporate debt obligations include corporate bonds, debentures, notes, commercial paper and other similar corporate debt instruments. Companies use these instruments to borrow money from investors. The issuer pays the investor a fixed or variable rate of interest and must repay the amount borrowed at maturity. Commercial paper (short-term unsecured promissory notes) is issued by companies to finance their current obligations and normally has a maturity of less than nine months. In addition, the firm may also invest in corporate debt securities registered and sold in the United States by foreign issuers (Yankee bonds) and those sold outside the U.S. by foreign or U.S. issuers (Eurobonds). Preferred Securities Preferred securities typically are considered to be between standard debt and equity in the capital structure, and can have both bond-like and stock-like qualities. They are generally subject to both types of risks, including interest rate, credit, and prepayment or call risk, as well as deferral or omission of distributions, subordination to bonds and more senior debt, and limited voting rights. Because the preferred securities market is comprised primarily of Page 17 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss securities issued by companies in the financial services industry, these securities may have greater industry-specific risk and changing tax treatments. Furthermore, certain preferred securities have a fixed-to-floating rate structure, meaning that they pay a fixed coupon rate for a specified period of time and then convert to a floating rate coupon for the duration of the issuance or until the security is called. The dividend rate on fixed-to-floating rate preferred securities may be more susceptible to decline when interest rates are falling. A secondary risk associated with declining interest rates is the risk that income earned by an account on floating rate securities may decline due to lower coupon payments on the floating-rate securities. Convertible Securities Convertible securities are subject to the risks of stocks when the underlying stock price is high relative to the conversion price (because more of the security’s value resides in the conversion feature) and debt securities when the underlying stock price is low relative to the conversion price (because the conversion feature is less valuable). A convertible security is not as sensitive to interest rate changes as a similar non-convertible debt security, and generally have less potential for gain or loss than the underlying stock. Interest-rate movements may affect the share price and yield. Bond prices generally move in the opposite direction of interest rates. As such, as the price of bonds adjust to a rise in interest rates, the bonds share price may decline. Structured Products Structured notes are fixed income securities that are issued by financial institutions with returns that are linked to or based on, among other things, equity indices, a single equity security, a basket of equity securities, interest rates, commodities, debt securities, exchange traded funds, and/or foreign currencies (a “Structured Note”). The security, asset, or index on which a Structured Note is based is often called the “Reference Instrument.” Structured Notes have a fixed maturity date and include two components – a bond component and an embedded derivative. While some Structured Notes offer substantial protection of invested principal, others offer limited or no principal protection. 
 The embedded derivatives within Structured Notes adjust the note's risk/return profile by including additional modifying structures that can increase potential returns. The return performance of a Structured Note typically tracks the return profile of the underlying debt obligation and the derivative that is embedded within it. Instead of simply paying straight fixed or floating interest, Structured Notes can offer interest payments that are tailored to specific indices and/or rates. The derivative securities that are embedded in the Structured Note can also positively or negatively affect the redemption value and final maturity of the security. Depending on complexity, risk profile, and numerous other factors, Structured Notes often pay interest or coupon rates that are above the prevailing market rate. Many Structured Notes cap or limit the amount of upside participation in the Reference Instrument or underlying asset, particularly in cases where the Structured Note offers principal protection or pays interest that Page 18 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss is above-market. Structured Notes are typically issued by investment banks or their affiliates, and feature a fixed maturity date. Structured Notes are not suitable for everyone. All investors assume full credit risk of the security’s issuer and/or guarantor. This means that the investor may lose all the monies invested, including all initial amounts invested as principal protection may not apply, if the issuer and/or the guarantor become insolvent or fail in any way. Each Structured Note involves varying degrees of risk and unique suitability issues that investors must consider before investing in such securities. Structured Notes involve important legal and tax consequences and investment risks, which each investor should discuss with qualified financial, accounting, and tax advisors regarding the suitability of the specific Structured Note in light of each investor’s particular circumstances. Understanding the Risk Factors. Before investing in any Structured Note security, it is important that you read the pricing supplement, accompanying prospectus, and prospectus supplements to ensure that you understand the risks associated with the specific Structured Note that you are purchasing. Payment terms vary significantly for each Structured Note depending on the structure and component of the specific security. While some Structured Notes may pay interest prior to liquidation, others may include payments only upon maturity. Additionally, rates of return vary based on many factors, including the performance of the underlying securities, assets, indices, and/or commodities. 
 Unless a Structured Note is specifically stated to be 100% principal protected or FDIC insured, some or all of your invested principal may be at risk. The return of your principal is guaranteed only to the extent specified in the specific offering terms for the Structured Note security you are purchasing, and is specifically subject to the credit and creditworthiness of the issuer and the underwriter. If there is a negative return on the underlying security or Reference Instrument, then you may receive an amount that is less than your invested principal at maturity and you could lose up to the percentage indicated in your initial investment terms. In some cases, you may end up owning the underlying security at a price that is lower than the original purchase price. As discussed in the risk factor explanation below, you are also advised that, in cases where the return on the underlying securities is positive, payment may be limited if the structure includes a cap on the percentage return for the underlying security or depending on how the percentage increase for the underlying security is calculated as of the determination date. You are also advised that it may be difficult to sell or liquidate the Structured Note or underlying security as there may be little or no secondary market for such securities, and independent market pricing may be limited or unavailable and market values may vary based on a variety of factors affecting the underlying securities or assets. Such factors may include, among other things: time to maturity; appreciation or depreciation of underlying securities; market volatility; interest rate fluctuations; and myriad other events that that may positively or negatively affect the value of underlying securities, indices, or assets. Page 19 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Issuance price and note value. The price you will pay for a Structured Note at the time of issuance will often be higher than the fair market value of the Structured Note on the date of issuance. The cover page of the offering prospectus discloses the issuer’s estimated value of the Structured Note in order to enable you to note the difference between the issuance price and the issuer’s estimated value of the note. The issuance price of the note is typically higher than the estimated market value of the note because issuers include in the initial price the costs for selling, structuring, and/or hedging their exposure on the note. Additionally, Structured Notes often may not be resold on a daily basis, which makes it difficult to value them, particularly given their complexity as compared to other financial products. Liquidity. With the exception of Exchange Traded Notes (“ETNs”), Structured Notes are typically not listed on any national securities exchange and can be difficult to sell, trade, or liquidate, especially in any large quantity or within any limited period of time. Although some Structured Notes are listed on national securities exchanges, such securities are often thinly traded and difficult to sell, trade, or liquidate. As a result, the issuing financial institution’s broker-dealer affiliate or the broker-dealer distributor of the note may be the only potential buyers for your Structured Note, and many issuers often specifically disclaim their intention to repurchase or make markets in the notes that they issue. If you choose to invest in a Structured Note, you must be prepared to hold the note until it reaches the maturity date, or bear the risk of selling the note at a discount to its value at the time of sale. Payoff structure. Structured Notes often have complicated payoff structures that make it difficult to accurately assess their value, risk, and growth potential over the term of the note. It can be complex to determine each note’s performance, as the payoff structures and features vary considerably among different notes. For example, payoff structures may be leveraged, inverse, or inverse-leveraged, which can result in larger returns or losses for the investor. You should review the prospectus and pricing supplements carefully for each Structured Note to ensure that you thoroughly understand how the payoff on each note will be calculated. For example, the payoff on Structured Notes can depend on: Participation rates. Many Structured Notes provide a minimum payoff of the invested principal plus an additional payoff amount to the investor. This is calculated by multiplying the increase in the Reference Instrument by a fixed percentage, which is often called the “participation rate.” The participation rate determines how much of the increase in the Reference Instrument will be paid to you a purchaser of the Structured Note. Capped maximum returns. Some Structured Notes provide payments that are linked to a Reference Instrument with a leveraged or enhanced participation rate, but the payoff amount is capped at a pre-set maximum payoff amount. This means that the investor does not participate in any increase in the Reference Instrument above the maximum payoff level. Knock-in feature. Structured Notes often include a pre-specified threshold for the Reference Instrument that is called a knock-in feature (also known as a barrier or trigger) that affects the payout return on the note. If the Reference Instrument falls below a pre-specified level during the term of the note, you could lose some or all of your principal investment at maturity. You could also lose the coupon payments scheduled throughout the term of the note. Page 20 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss Credit Rating. While many Structured Notes, Reference Instruments, and underlying securities may be assigned a credit rating from a national rating organization, many Structured Notes and underlying securities have no credit rating. To the extent that a particular credit rating may pertain to the creditworthiness of the issuer, it is not necessarily indicative of the risk associated with a specific Structured Note or Reference Instrument, index, or asset. The presentation of a credit rating in relation to any Structured Note or underlying security may not indicate or reflect the safety of the principal invested or the potential investment returns associated with the investment. Such credit ratings may not affect or enhance the likely performance of the Structured Note investment.
 Tax
. The Structured Note investment may be treated as a “contingent payment debt instrument” for U.S. federal income tax purposes. Consequently, even in cases where any accrued interest is not payable until maturity, investors may be required to accrue such interest as ordinary income based on the “comparable yield” of the underlying securities as determined by the underwriter. ZFA strongly recommends that you consult your tax advisor regarding such tax treatment and implications prior to purchasing any Structured Note security. B. Investment Strategy and Method of Analysis Material Risks Our investment strategy is custom-tailored to the client’s goals, investment objectives, risk tolerance, and personal and financial circumstances. Margin Leverage Although ZFA, as a general business practice, does not utilize leverage, there may be instances in which exchange-traded funds, other separate account managers and, in very limited circumstances, ZFA will utilize leverage. In this regard please review the following: The use of margin leverage enhances the overall risk of investment gain and loss to the client’s investment portfolio. For example, investors are able to control $2 of a security for $1. So if the price of a security rises by $1, the investor earns a 100% return on their investment. Conversely, if the security declines by $.50, then the investor loses 50% of their investment. The use of margin leverage entails borrowing, which results in additional interest costs to the investor. Broker-dealers who carry customer accounts require a minimum equity requirement when clients utilize margin leverage. The minimum equity requirement is stated as a percentage of the value of the underlying collateral security with an absolute minimum dollar requirement. For example, if the price of a security declines in value to the point where the excess equity used to satisfy the minimum requirement dissipates, the broker-dealer will require the client to deposit additional collateral to the account in the form of cash or marketable securities. A deposit of securities to the account will require a larger deposit, as the security being deposited is included in the computation of the minimum equity requirement. In addition, when leverage is utilized and the client needs to withdraw cash, the client must sell a disproportionate amount of Page 21 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss collateral securities to release enough cash to satisfy the withdrawal amount based upon similar reasoning as cited above. Regulations concerning the use of margin leverage are established by the Federal Reserve Board and vary if the client’s account is held at a broker-dealer versus a bank custodian. Broker-dealers and bank custodians may apply more stringent rules as they deem necessary. Short-Term Trading Although ZFA, as a general business practice, does not utilize short-term trading, there may be instances in which short-term trading may be necessary or an appropriate strategy. In this regard, please read the following: There is an inherent risk for clients who trade frequently in that high-frequency trading creates substantial transaction costs that in the aggregate could negatively impact account performance. C. Security-Specific Material Risks There is an inherent risk for clients who have their investment portfolios heavily weighted in one security, one industry or industry sector, one geographic location, one investment manager, one type of investment instrument (equities versus fixed income). Clients who have diversified portfolios, as a general rule, incur less volatility and therefore less fluctuation in portfolio value than those who have concentrated holdings. Concentrated holdings may offer the potential for higher gain, but also offer the potential for significant loss. Page 22 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 9: Disciplinary Information Item 9: Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s evaluation of ZFA or the integrity of ZFA’s management. ZFA has no disciplinary events to report. A. Criminal or Civil Actions There is nothing to report on this item. B. Administrative Enforcement Proceedings There is nothing to report on this item. C. Self-Regulatory Organization Enforcement Proceedings There is nothing to report on this item. Page 23 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 10: Other Financial Industry Activities and Affiliations Item 10: Other Financial Industry Activities and Affiliations A. Broker-Dealer or Representative Registration Neither ZFA nor its affiliates, employees, or independent contractors are registered broker- dealers and do not have an application to register pending. B. Futures or Commodity Registration Neither ZFA nor its affiliates are registered as a commodity firm, futures commission merchant, commodity pool operator or commodity trading advisor and do not have an application to register pending. C. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Ann Zuraw co-authored a children’s book with an investment advisory client. Please be advised that this activity creates a conflict of interest in that Ms. Zuraw may have an economic incentive to favor this client over other clients. ZFA has policies and procedures in place to ensure the firm’s advisory personnel act in the best interests of clients and that no client receives more favorable treatment than other clients. D. Recommendation or Selection of Other Investment Advisors and Conflicts of Interest Although ZFA does not receive any remuneration from advisers, investment managers, or other service providers that it recommends to clients, the firm engages sub-advisers to manage ZFA client accounts and receives a portion of the advisory fees charged by ZFA for its investment management services. Page 24 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Description In accordance with the Advisers Act, ZFA has adopted policies and procedures designed to detect and prevent insider trading. In addition, ZFA has adopted a Code of Ethics (the “Code”). Among other things, the Code includes written procedures governing the conduct of ZFA's advisory and access persons. The Code also imposes certain reporting obligations on persons subject to the Code. The Code and applicable securities transactions are monitored by the chief compliance officer of ZFA. ZFA will send clients a copy of its Code of Ethics upon written request. ZFA has policies and procedures in place to ensure that the interests of its clients are given preference over those of ZFA, its affiliates and its employees. For example, there are policies in place to prevent the misappropriation of material non-public information, and such other policies and procedures reasonably designed to comply with federal and state securities laws. B. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest ZFA does not engage in principal trading (i.e., the practice of selling stock to advisory clients from a firm’s inventory or buying stocks from advisory clients into a firm’s inventory). In addition, ZFA does not recommend any securities to advisory clients in which it has some proprietary ownership interest. C. Advisory Firm Purchase or Sale of Same Securities Recommended to Clients and Conflicts of Interest ZFA, its affiliates, employees and their families, trusts, estates, charitable organizations and retirement plans established by it may purchase or sell the same securities as are purchased or sold for clients in accordance with its Code of Ethics policies and procedures. The personal securities transactions by advisory representatives and employees may raise potential conflicts of interest when they trade in a security that is: ▪ owned by the client, or ▪ considered for purchase or sale for the client. Such conflict generally refers to the practice of front-running (trading ahead of the client), which ZFA specifically prohibits. ZFA has adopted policies and procedures that are intended to address these conflicts of interest. These policies and procedures: ▪ require our advisory representatives and employees to act in the client’s best interest, ▪ prohibit front-running, and ▪ provide for the review of transactions to discover and correct any trades that result in an advisory representative or employee benefitting at the expense of a client. Page 25 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Advisory representatives and employees must follow ZFA’s procedures when purchasing or selling the same securities purchased or sold for the client. D. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest ZFA, its affiliates, employees and their families, trusts, estates, charitable organizations, and retirement plans established by it may effect securities transactions for their own accounts that differ from those recommended or effected for other ZFA clients. ZFA will make a reasonable attempt to trade securities in client accounts at or prior to trading the securities in its affiliate, corporate, employee or employee-related accounts. Trades executed the same day will likely be subject to an average pricing calculation (please refer to Item 12.B.3 Order Aggregation). It is the policy of ZFA to place the clients’ interests above those of ZFA and its employees. Page 26 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 12: Brokerage Practices Item 12: Brokerage Practices A. Factors Used to Select Broker-Dealers for Client Transactions Custodian Recommendations ZFA may recommend that clients establish brokerage accounts with Schwab Advisor Services division of Charles Schwab & Co., Inc., or with Fidelity Investments (collectively “custodian”), FINRA registered broker-dealers, members SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although ZFA may recommend that clients establish accounts at the custodian, it is the client’s decision to custody assets with the custodian. ZFA is independently owned and operated and not affiliated with custodian. For ZFA client accounts maintained in its custody, the custodian generally does not charge separately for custody services but is compensated by account holders through commissions and other transaction- related or asset-based fees for securities trades that are executed through the custodian or that settle into custodian accounts. ZFA considers the financial strength, reputation, operational efficiency, cost, execution capability, level of customer service, and related factors in recommending broker-dealers or custodians to advisory clients. In certain instances and subject to approval by ZFA, ZFA will recommend to clients certain other broker-dealers and/or custodians based on the needs of the individual client, and taking into consideration the nature of the services required, the experience of the broker-dealer or custodian, the cost and quality of the services, and the reputation of the broker-dealer or custodian. The final determination to engage a broker-dealer or custodian recommended by ZFA will be made by and in the sole discretion of the client. The client recognizes that broker- dealers and/or custodians have different cost and fee structures and trade execution capabilities. As a result, there may be disparities with respect to the cost of services and/or the transaction prices for securities transactions executed on behalf of the client. Clients are responsible for assessing the commissions and other costs charged by broker-dealers and/or custodians. How We Select Brokers/Custodians to Recommend ZFA seeks to recommend a custodian/broker who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others, the following: ▪ combination of transaction execution services along with asset custody services (generally without a separate fee for custody) ▪ capability to execute, clear, and settle trades (buy and sell securities for client accounts) ▪ capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) ▪ breadth of investment products made available (stocks, bonds, mutual funds, exchange- traded funds (ETFs), etc.) Page 27 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 12: Brokerage Practices ▪ availability of investment research and tools that assist us in making investment decisions ▪ quality of services ▪ competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them ▪ reputation, financial strength, and stability of the provider ▪ their prior service to us and our other clients ▪ availability of other products and services that benefit us, as discussed below Client’s Custody and Brokerage Costs For client accounts that the firm maintains, the custodian generally does not charge clients separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into the custodian’s accounts. The custodian’s commission rates applicable to the firm’s client accounts were negotiated based on the firm’s commitment to maintain a certain minimum amount of client assets at the custodian. This commitment benefits the client because the overall commission rates paid are lower than they would be if the firm had not made the commitment. In addition to commissions, the custodian charges a flat dollar amount as a “prime broker” or “trade away” fee for each trade that the firm has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into the client’s custodian account. These fees are in addition to the commissions or other compensation the client pays the executing broker- dealer. Because of this, in order to minimize the client’s trading costs, the firm has the custodian execute most trades for the account. Soft Dollar Arrangements ZFA does not utilize soft dollar arrangements. ZFA does not direct brokerage transactions to executing brokers for research and brokerage services. Institutional Trading and Custody Services The custodian provides ZFA with access to its institutional trading and custody services, which are typically not available to the custodian’s retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a certain minimum amount of the advisor’s clients’ assets are maintained in accounts at a particular custodian. The custodian’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Other Products and Services Custodian also makes available to ZFA other products and services that benefit ZFA but may not directly benefit its clients’ accounts. Many of these products and services may be used to service all or some substantial number of ZFA's accounts, including accounts not maintained Page 28 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 12: Brokerage Practices at custodian. The custodian may also make available to ZFA software and other technology that ▪ provide access to client account data (such as trade confirmations and account statements) ▪ facilitate trade execution and allocate aggregated trade orders for multiple client accounts ▪ provide research, pricing and other market data ▪ facilitate payment of ZFA’s fees from its clients’ accounts ▪ assist with back-office functions, recordkeeping and client reporting The custodian may also offer other services intended to help ZFA manage and further develop its business enterprise. These services may include ▪ compliance, legal and business consulting ▪ publications and conferences on practice management and business succession ▪ access to employee benefits providers, human capital consultants and insurance providers The custodian may also provide other benefits such as educational events or occasional business entertainment of ZFA personnel. In evaluating whether to recommend that clients custody their assets at the custodian, ZFA may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors it considers, and not solely the nature, cost or quality of custody and brokerage services provided by the custodian, which may create a potential conflict of interest. Independent Third Parties The custodian may make available, arrange, and/or pay third-party vendors for the types of services rendered to ZFA. The custodian may discount or waive fees it would otherwise charge for some of these services or all or a part of the fees of a third party providing these services to ZFA. Additional Compensation Received from Custodians ZFA may participate in institutional customer programs sponsored by broker-dealers or custodians. ZFA may recommend these broker-dealers or custodians to clients for custody and brokerage services. There is no direct link between ZFA’s participation in such programs and the investment advice it gives to its clients, although ZFA receives economic benefits through its participation in the programs that are typically not available to retail investors. These benefits may include the following products and services (provided without cost or at a discount): ▪ Receipt of duplicate client statements and confirmations ▪ Research-related products and tools ▪ Consulting services ▪ Access to a trading desk serving ZFA participants Page 29 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 12: Brokerage Practices ▪ Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts) ▪ The ability to have advisory fees deducted directly from client accounts ▪ Access to an electronic communications network for client order entry and account information ▪ Access to mutual funds with no transaction fees and to certain institutional money managers ▪ Discounts on compliance, marketing, research, technology, and practice management products or services provided to ZFA by third-party vendors The custodian may also pay for business consulting and professional services received by ZFA’s related persons, and may pay or reimburse expenses (including travel, lodging, meals and entertainment expenses for ZFA’s personnel to attend conferences). Some of the products and services made available by such custodian through its institutional customer programs may benefit ZFA but may not benefit its client accounts. These products or services may assist ZFA in managing and administering client accounts, including accounts not maintained at the custodian as applicable. Other services made available through the programs are intended to help ZFA manage and further develop its business enterprise. The benefits received by ZFA or its personnel through participation in these programs do not depend on the amount of brokerage transactions directed to the broker-dealer. ZFA also participates in similar institutional advisor programs offered by other independent broker-dealers or trust companies, and its continued participation may require ZFA to maintain a predetermined level of assets at such firms. In connection with its participation in such programs, ZFA will typically receive benefits similar to those listed above, including research, payments for business consulting and professional services received by ZFA’s related persons, and reimbursement of expenses (including travel, lodging, meals and entertainment expenses for ZFA’s personnel to attend conferences sponsored by the broker-dealer or trust company). As part of its fiduciary duties to clients, ZFA endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by ZFA or its related persons in and of itself creates a potential conflict of interest and may indirectly influence ZFA’s recommendation of broker-dealers for custody and brokerage services. The Firm’s Interest in Custodian Services The availability of these services from the custodian benefits the firm because the firm does not have to produce or purchase them. The firm does not have to pay for the custodian’s services so long as a certain minimum of client assets is kept in accounts at the custodian. This minimum of client assets may give the firm an incentive to recommend that clients maintain their accounts with the custodian based on the firm’s interest in receiving the custodian’s services that benefit the firm’s business rather than based on the client’s interest in receiving the best value in custody services and the most favorable execution of client transactions. This is a potential conflict of interest. The firm believes, however, that the selection of the custodian as custodian and broker is in the best interest of clients. It is primarily supported by the scope, Page 30 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 12: Brokerage Practices quality, and price of the custodian’s services and not the custodian’s services that benefit only the firm. Brokerage for Client Referrals ZFA does not engage in the practice of directing brokerage commissions in exchange for the referral of advisory clients. Directed Brokerage ZFA Recommendations ZFA typically recommends Schwab or Fidelity as custodian for clients’ funds and securities and to execute securities transactions on its clients’ behalf. Client-Directed Brokerage Occasionally, clients may direct ZFA to use a particular broker-dealer to execute portfolio transactions for their account or request that certain types of securities not be purchased for their account. Clients who designate the use of a particular broker-dealer should be aware that they will lose any possible advantage ZFA derives from aggregating transactions. Such client trades are typically effected after the trades of clients who have not directed the use of a particular broker-dealer. ZFA loses the ability to aggregate trades with other ZFA advisory clients, potentially subjecting the client to inferior trade execution prices as well as higher commissions. B. Aggregating Securities Transactions for Client Accounts Best Execution ZFA, pursuant to the terms of its investment advisory agreement with clients, has discretionary authority to determine which securities are to be bought and sold, the amount of such securities, the executing broker, and the commission rates to be paid to effect such transactions. ZFA recognizes that the analysis of execution quality involves a number of factors, both qualitative and quantitative. ZFA will follow a process in an attempt to ensure that it is seeking to obtain the most favorable execution under the prevailing circumstances when placing client orders. These factors include but are not limited to the following: ▪ The financial strength, reputation and stability of the broker ▪ The efficiency with which the transaction is effected ▪ The ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any) ▪ The availability of the broker to stand ready to effect transactions of varying degrees of difficulty in the future ▪ The efficiency of error resolution, clearance and settlement ▪ Block trading and positioning capabilities Page 31 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 12: Brokerage Practices ▪ Performance measurement ▪ Online access to computerized data regarding customer accounts ▪ Availability, comprehensiveness, and frequency of brokerage and research services ▪ Commission rates ▪ The economic benefit to the client ▪ Related matters involved in the receipt of brokerage services Consistent with its fiduciary responsibilities, ZFA seeks to ensure that clients receive best execution with respect to clients’ transactions by blocking client trades to reduce commissions and transaction costs. To the best of ZFA’s knowledge, these custodians provide high-quality execution, and ZFA’s clients do not pay higher transaction costs in return for such execution. Commission rates and securities transaction fees charged to effect such transactions are established by the client’s independent custodian and/or broker-dealer. Based upon its own knowledge of the securities industry, ZFA believes that such commission rates are competitive within the securities industry. Lower commissions or better execution may be able to be achieved elsewhere. Security Allocation Since ZFA may be managing accounts with similar investment objectives, ZFA may aggregate orders for securities for such accounts. In such event, allocation of the securities so purchased or sold, as well as expenses incurred in the transaction, is made by ZFA in the manner it considers to be the most equitable and consistent with its fiduciary obligations to such accounts. ZFA’s allocation procedures seek to allocate investment opportunities among clients in the fairest possible way, taking into account the clients’ best interests. ZFA will follow procedures to ensure that allocations do not involve a practice of favoring or discriminating against any client or group of clients. Account performance is never a factor in trade allocations. ZFA’s advice to certain clients and entities and the action of ZFA for those and other clients are frequently premised not only on the merits of a particular investment, but also on the suitability of that investment for the particular client in light of his or her applicable investment objective, guidelines and circumstances. Thus, any action of ZFA with respect to a particular investment may, for a particular client, differ or be opposed to the recommendation, advice, or actions of ZFA to or on behalf of other clients. Order Aggregation Orders for the same security entered on behalf of more than one client will generally be aggregated (i.e., blocked or bunched) subject to the aggregation being in the best interests of all participating clients. Subsequent orders for the same security entered during the same trading day may be aggregated with any previously unfilled orders. Subsequent orders may also be aggregated with filled orders if the market price for the security has not materially changed and the aggregation does not cause any unintended duration exposure. All clients participating in each aggregated order will receive the average price and, subject to minimum ticket charges and possible step outs, pay a pro rata portion of commissions. Page 32 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 12: Brokerage Practices To minimize performance dispersion, “strategy” trades should be aggregated and average priced. However, when a trade is to be executed for an individual account and the trade is not in the best interests of other accounts, then the trade will only be performed for that account. This is true even if ZFA believes that a larger size block trade would lead to best overall price for the security being transacted. Allocation of Trades All allocations will be made prior to the close of business on the trade date. In the event an order is “partially filled,” the allocation will be made in the best interests of all the clients in the order, taking into account all relevant factors including, but not limited to, the size of each client’s allocation, clients’ liquidity needs and previous allocations. In most cases, accounts will get a pro forma allocation based on the initial allocation. This policy also applies if an order is “over-filled.” ZFA acts in accordance with its duty to seek best price and execution and will not continue any arrangements if ZFA determines that such arrangements are no longer in the best interest of its clients. Page 33 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 13: Review of Accounts Item 13: Review of Accounts A. Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Managed portfolios are reviewed by Ann Zuraw, ZFA’s Managing Member. Managed portfolios are reviewed at least quarterly, but may be reviewed more often if requested by the client, upon receipt of information material to the management of the portfolio, or at any time such review is deemed necessary or advisable by ZFA. These factors may include but are not limited to, the following: change in general client circumstances (marriage, divorce, retirement); or economic, political or market conditions. Financial planning clients receive their financial plans online and recommendations at the time service is completed. There are no post-plan reviews unless engaged to do so by the client. B. Review of Client Accounts on Non-Periodic Basis ZFA may perform ad hoc reviews on an as-needed basis if there have been material changes in the client’s investment objectives or risk tolerance, or a material change in how ZFA formulates investment advice. C. Content of Client-Provided Reports and Frequency Through Advyzon, clients will have access to their account information and performance. Clients will be provided with a unique login and password through which they can access the Advyzon portal. The client’s independent custodian provides account statements directly to the client no less frequently than quarterly. The custodian’s statement is the official record of the client’s securities account and supersedes any statements or reports created on behalf of the client by ZFA. Page 34 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 14: Client Referrals and Other Compensation Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Custodian Benefits ZFA receives an economic benefit from custodians in the form of the support products and services they make available to us. These products and services, how they benefit us, and the related conflicts of interest are described under Item 12: Brokerage Practices. The availability to us of custodians’ products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Nitrogen “No Platform Fee” Discount Program ZFA is eligible to participate in Nitrogen’s “No Platform Fee” discount program and may receive discounts on our technology expense from Nitrogen through our participation in the program. The receipt of the discounts creates a financial incentive for us to recommend certain exchange- traded funds, mutual funds, and separately managed portfolios that make us eligible for the discounts over others that would be in your best interest (such as where they are less expensive or have better performance). This financial incentive creates a conflict of interest. B. Advisory Firm Payments for Client Referrals ZFA does not pay for client referrals. Page 35 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 15: Custody Item 15: Custody ZFA is considered to have custody of client assets for purposes of the Advisers Act for the following reasons: ▪ The client authorizes us to instruct their custodian to deduct our advisory fees directly from the client’s account. The custodian maintains actual custody of clients’ assets. ▪ Our authority to direct client requests, utilizing standing instructions, for wire transfer of funds for first-party money movement and third-party money movement (checks and/or journals, ACH, Fed-wires). The firm has elected to engage an independent public accountant to annually conduct a surprise custody exam audit. Individual advisory clients will receive at least quarterly account statements directly from their custodian containing a description of all activity, cash balances, and portfolio holdings in their accounts. Clients are urged to compare the account balance(s) shown on their account statements to the quarter-end balance(s) on their custodian's monthly statement. The custodian’s statement is the official record of the account. Private fund investors will receive fund level statements of all activity, cash balances, and portfolio holdings on a quarterly basis from their qualified custodian. Page 36 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 16: Investment Discretion Item 16: Investment Discretion Clients may grant a limited power of attorney to ZFA with respect to trading activity in their accounts by signing the appropriate custodian limited power of attorney form. In those cases, ZFA will exercise full discretion as to the nature and type of securities to be purchased and sold, the amount of securities for such transactions, the executing broker to be used, and the amount of commissions to be paid. Investment limitations may be designated by the client as outlined in the investment advisory agreement. In addition, subject to the terms of its investment advisory agreement, ZFA may be granted discretionary authority for the retention of independent third- party investment management firms. Investment limitations may be designated by the client as outlined in the investment advisory agreement. Please see the applicable third-party manager’s disclosure brochure for detailed information relating to discretionary authority. Page 37 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 17: Voting Client Securities Item 17: Voting Client Securities Other than for accounts managed by third-party managers or accounts where the client directs the trading, ZFA will vote proxies for clients utilizing the Broadridge proxy voting platform. Third-party managers will vote proxies on securities held in their portfolios. ZFA owes certain fiduciary duties with respect to the voting of proxies. These fiduciary duties include (i) the duty of care which is required to monitor corporate events and to vote the proxies, and (ii) the duty of loyalty which is required to vote proxies in a manner consistent with the best interests of the client and to put the client's interests before its own interests. In keeping with its fiduciary duties, ZFA has adopted a Proxy Voting Policy, which sets forth policies and procedures designed to ensure that ZFA votes each client's securities in the best interests of the client. ZFA will be authorized to act and render any advice with respect to the voting of proxies for securities held in the client’s account. ZFA will make an independent valuation for each applicable company held in the client’s account in accordance with its fiduciary obligations as detailed in this policy. Clients may contact ZFA’s Managing Member for information about how ZFA voted with respect to any of the securities held in their account. Except as required by applicable law, ZFA will not be obligated to render advice or take any action on behalf of the client with respect to assets presently or formerly held in the client’s account which become the subject of any legal proceedings, including bankruptcies. From time to time, securities held in the accounts of clients will be the subject of class action lawsuits. ZFA has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. ZFA also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, ZFA has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured because of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. Where ZFA receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a client, it will forward all notices, proof of claim forms, and other materials to the client. Electronic mail is acceptable where appropriate and where the client has authorized contact in this manner. As a rule, ZFA will vote all proxies relating to a particular proposal the same way for all client accounts holding the security in accordance with ZFA’s Proxy Voting Policy, unless a client specifically instructs in writing to vote such client's securities otherwise. When making proxy voting decisions, ZFA may seek advice or assistance from third-party consultants, such as proxy voting services or legal counsel. A copy of ZFA’s Proxy Voting Policy will be provided upon receipt of a written request. Page 38 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure  Item 18: Financial Information Item 18: Financial Information A. Balance Sheet ZFA does not require the prepayment of fees of $1200 or more, six months or more in advance, and as such is not required to file a balance sheet. B. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ZFA does not have any financial issues that would impair its ability to provide services to clients. C. Bankruptcy Petitions During the Past Ten Years There is nothing to report on this item. Page 39 Part 2A of Form ADV: Zuraw Financial Advisors, LLC Brochure